It is a basic requirement of approval that traders operate in
a reasonably transparent way. Where traders appear to lack
transparency, either in their organisation or their dealings with
excise goods, officers must question and consider whether the
trader’s activity compromises our ability to gain an
acceptable level of assurance or represents a higher than
acceptable revenue risk. If either is the case, officers should
seek an explanation from the trader. If the explanation is not
credible or satisfactory, officers must consider whether continued
approval is justified given any risks identified. See X99 Approvals
and Registrations guidance for further information.
